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Cooperation

3 Key Takeaways: Foreign Corrupt Practices Act Trends in 2017

Kilpatrick Townsend partner Adria Perez recently presented to the Association of Corporate Counsel (ACC) Georgia Chapter about key 2017 trends concerning the enforcement of Foreign Corrupt Practices Act (“FCPA”) against...more

CFTC’s Enforcement Division Announces New Focus on Self-Reporting

Upon discovering a potential violation, a company is often faced with the dilemma of whether to self-report the incident to its regulator or attempt to deal with the incident through exclusively internal means. On September...more

CFTC’s Updated Enforcement Advisory Attempts To Shift Incentives In Favor Of Self-Reporting And Full Cooperation

On September 25, 2017, the Division of Enforcement (Division) of the US Commodity Futures Trading Commission (Commission) issued an “Updated Advisory On Self Reporting And Full Cooperation.” The Enforcement Advisory was...more

When the Inevitable Happens: When to Self-Report Securities Law Violations and What to Expect When You Do

by WilmerHale on

An anonymous compliance hotline within your investment adviser suddenly receives complaints about a market-beating portfolio manager. Your in-house compliance and legal team investigate and learn this portfolio manager may...more

New CFTC Enforcement Policy Encourages Self-Reporting

by WilmerHale on

In January of this year, the Commodity Futures Trading Commission's (CFTC or Commission) Division of Enforcement (the Division) issued revised cooperation credit guidelines for companies, and its first-ever cooperation...more

New CFTC Director of Enforcement Incentivizes Self-Reporting, Counts on “Buy-in” From Market Participants

by King & Spalding on

In prepared remarks at New York University’s School of Law on September 25, 2017, the newly minted Director of Enforcement at the U.S. Commodity Futures Trading Commission passionately outlined the contours of the CFTC’s new...more

China’s ‘One Belt, One Road’ Initiative Creates Opportunities and Regulatory Challenges

In a time of shifting opinions on the benefits of globalization, China’s “One Belt, One Road” initiative (OBOR) offers an unexpected bright spot for multinational companies able and willing to participate in this...more

Infusing Corporate Culture with Accountability

by Michael Volkov on

If you are a fan of Simon Sinek, you will understand and probably agree with the thrust of this posting. Sinek is a great motivational and business speaker. Many of his observations are spot-on and I would urge you to review...more

This Week In Securities Litigation

by Dorsey & Whitney LLP on

The SEC filed an insider trading case this week based on three separate trading chains that netted $5 million in trading profits, all back to a New York City bank official. The Manhattan U.S. Attorney’s Office filed a...more

What Is The Value of Cooperation With the SEC?

by Dorsey & Whitney LLP on

The Commission has long encouraged firms and individuals to cooperate with its investigations based on the promise of consideration when the action is resolved. When the resolution is reached the agency may acknowledge the...more

Piercing The Corporate Veil In Texas

by Fox Rothschild LLP on

Texas has long been one of the best locations to start a business, and a big reason for this is the liability protection afforded by the business-friendly Texas courts. Most business owners seek to limit their personal...more

EU Commission Exposes Automotive Lighting Cartel

by Bryan Cave on

On 21st June 2017 the European Commission announced that it had fined Automotive Lighting and Hella over €26 million for participating in an automotive lighting cartel, in breach of Article 101 of the Treaty for the...more

FCPA: 2017 Mid-Year Review Webinar

by Bryan Cave on

Enforcement of the Foreign Corrupt Practices Act was a high priority for the Department of Justice and the Securities and Exchange Commission in 2016. There's interest in how the new administration could impact enforcement as...more

Law Society practice note on legal professional privilege: call-to-arms or helpful restatement?

by WilmerHale on

This article considers the Law Society practice note on legal professional privilege (LPP) published on 23 February 2017, in the light of public statements by the UK's Serious Fraud Office (SFO) that companies under...more

Red Notice Newsletter - Russian

ANTICORRUPTION DEVELOPMENTS – Former Magyar Telekom Executives Settle Bribery Charges – On April 24, 2017, the Securities and Exchange Commission (SEC) announced that two former executives of Magyar Telekom, a...more

DOJ-Antitrust Revises Guidance on Coverage of "Current" Employees in Company Leniency Agreements

by Jones Day on

The U.S. Department of Justice's ("DOJ") Antitrust Division historically has extended leniency to cooperating companies and their current employees, even "highly culpable" employees who were very involved in the price-fixing...more

Every Little Helps with a DPA

by Dechert LLP on

Lord Justice Leveson approved Tesco Store Limited’s (“Tesco”) Deferred Prosecution Agreement (“DPA”) on 10 April 2017, making them the fourth company since November 2015 to enter into a DPA with the UK’s1 Serious Fraud Office...more

Evaluating FCPA Pilot Program: Lessons And Expectations

by WilmerHale on

On April 5, 2016, the U.S. Department of Justice released a nine-page memorandum launching a one-year pilot program to reward companies that voluntarily self-report violations of the Foreign Corrupt Practices Act. Now...more

Tesco: The Serious Fraud Office secures its fourth Deferred Prosecution Agreement

by WilmerHale on

On 10 April 2017, the Serious Fraud Office (“SFO”) entered into a Deferred Prosecution Agreement (“DPA”) with Tesco Stores Limited (“Tesco Limited”), as part of which Tesco Limited will pay a £129 million financial penalty...more

Evaluating FCPA Pilot Program: The Data, The Trends

by Ropes & Gray LLP on

April 5 marked the one-year anniversary of the "Foreign Corrupt Practices Act Enforcement Plan and Guidance." Announced by the U.S. Department of Justice, Criminal Division's Fraud Section, the guidance outlined three...more

Sally Yates’ was Already Famous for Changing the Focus of Compliance Investigations - The Yates Memorandum

by Ruder Ware on

By now the whole world knows about Sally Yates. We are likely to see a lot more of her as a central figure in Congressional investigations. For some of us who deal with compliance investigations, Sally Yates was famous long...more

Self-Disclosure Analysis of FCPA violations and the New Administration

by Jackson Lewis P.C. on

On April 5, 2016, the Department of Justice had set forth a Foreign Corrupt Practices Act (“FCPA”) Enforcement Plan and Guidance on enforcement, announcing an FCPA enforcement pilot program to promote greater accountability...more

DOJ Announces Continuation and Ongoing Review of FCPA Pilot Program

by Latham & Watkins LLP on

The extension of the program — which emphasizes voluntary self-disclosure of FCPA violations, raises considerations for corporate entities and individual executives. The Department of Justice (DOJ) recently announced...more

Corporate Compliance Programs: US and UK Perspectives

by Dechert LLP on

In today’s regulatory environment, companies face mounting pressure from law enforcement agencies to maintain robust compliance programs to deter and detect misconduct by employees, third-party vendors and business partners....more

Updated Status of the DOJ FCPA Pilot Program

The FCPA Pilot Program was introduced on April 5, 2016 as a one year experiment that sought to ‘motivate companies to voluntarily self-disclose FCPA-related misconduct, fully cooperate with the Fraud Section and …remediate...more

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